IRS WILL NOT ISSUE ADVANCE RULINGS ON SOME SEC. 897 FOREIGNERS' REAL ESTATE SALES

Rev. Proc. 84-73

SECTION 1. BACKGROUND

Rev. Proc. 84-22, 1984-13 I.R.B. 18, sets forth areas in which advance rulings or determination letters will not be issued by the Internal Revenue Service. Section 4 of Rev. Proc. 84-22 is entitled "Areas in Which Rulings or Determination Letters Will Not Ordinarily Be Issued".

SEC. 2 PROCEDURE

Rev. Proc. 84-22 is hereby amended by adding to section 4.10 the following new section:

Section 897(e).--Coordination with Nonrecognition Provisions--Whether any nonrecognition provision shall apply for purposes of section 897, unless the transaction clearly falls within the provision of section 897(e)(1). See Rev. Rul. 84-160, page 6, this Bulletin.

SEC. 3. EFFECTIVE DATE

This revenue procedure will apply to all ruling requests on hand in the National Office on November 5, 1984, the date of publication of this revenue procedure in the Internal Revenue Bulletin, as well as to requests received thereafter.

SEC. 4. EFFECT ON OTHER REVENUE PROCEDURES

Rev. Proc. 84-22 is amplified.